A real and present danger to play provision

Before proceeding, however, I enter a plea. A plea that you stick with this article despite the fact that the subject may – until now – have been a turn-off. I say again: I am about to speak about a real and present danger.

The subject is play provision Standards, in this case a new Standard in respect of IAS (Impact Absorbing Surface) being proposed by ASTM’s (American Society for Testing and Materials) playground surfacing committee.

Do not imagine that any changes will affect only the USA. Eventually, the likelihood is that they will affect Standards across national boundaries.

Why a turn-off?

For those readers who want immediately to find out more about the detail and potential negative consequences of the proposed – and likely as not imminent – changes, skip the next eight paragraphs to get to more detail.

But I think it it useful before getting into detail to first say a few words as to why the subject of play equipment and surfacing Standards seem not to command the attention of those otherwise deeply concerned about, and often responsible for, children and teenagers’ play opportunities.

One possible reason for the ‘turn-off’ is that Standards are routinely presented as firmly located within the purview of ‘objective’ science, praying in aid ‘evidence-based’ data – a plethora of numbers attached to acronyms and abbreviations, seemingly impenetrable to ordinary folk. It all appears terribly, terribly technical and recondite. For experts only.

‘Evidence-based’ is the ground on which Standards formally stand. Yet, in their presentation to the wider world, an irony-laced twist occurs: the seemingly objective technical ‘facts of the matter’, now reified in a Standard, are promulgated as the irrefutable emanations of ‘common sense’ – beyond argument or counter-view. Yet, as in the case I speak of here, there can be substantial cause for doubt.

In fact, play equipment standards are shot through with barely acknowledged value-based assumptions through which the evidence – and what constitutes evidence here is a contested area – is weighed, shaped and filtered.

So far as Standard decision-making structures and processes are concerned, in practice they combine to form a quasi-private world, not easily susceptible to scrutiny or questioning by those daily working at play provision’s front line or, indeed, those concerned with national and local policy in respect of play. There is something distinctly biblical about the process of formulating Standards: it puts me in mind of Moses on Mount Sinai, out of sight to the multitudes below, cooking up with God the written ten commandments (and, lest you forget, 613 oral ones) and then delivering them to the not altogether enthusiastic People at mountain’s foot who nevertheless agree, perhaps in bemusement, to adhere to them.

Our responsibility too

Nevertheless, whilst there are legitimate grounds to question play equipment and surfacing Standards, along with the structures and processes that generate them, there must also be concern that those responsible for play provision – whether at the policy level or at the ‘front line’ – have largely failed to bring to the admittedly quasi-obscure world of Standard formulation, the values, insights and observation-based knowledge that animate the best of play provision. As suggested in our paper ‘Children’s Play Space and Safety Management: Rethinking the Role of Play Equipment Standards‘:

‘Play providers have in effect ceded their authority to make value-based decisions to forms of technical expertise….’

That quasi-obscurity, however, only identifies a difficulty, it cannot function as adequate excuse for absenting ourselves from debate, critique, or opposition to the current dispensations of Standard-making bodies.

The danger that prompted this piece lies in the ASTM (American Society for Testing and Materials) seeking to secure, may indeed have secured, a reduction in the Head Injury Criterion (HIC) value of Impact Absorbing Surfaces (IAS) from the current HIC1000 to HIC700.

The potential negative consequences are not difficult to understand. If this change is ratified, and it seems the wind is blowing in that direction, there are real fears that it will have counter-productive consequences on children and teenagers’ play provision, eventually pretty much worldwide.

The practical potential consequences of a reduction in HIC are quite straightforward. It will in practice confront play provision providers with the option to:

spend more on surfacing if fall heights remain constant

and/or lowering the current fall height to accommodate the revised Head Injury Criterion.

Thus, possible consequences include: a reduction in play provision overall because of increased costs or increased expenditure on only some existing playgrounds, with others closed or mothballed; a reduction in children and teenagers experience of risk; a furthering dumbing down of playgrounds; a general diminution of the play experience, along with the possibility that children and teenagers will seek the experience of height in places considered more potentially hazardous.

In addition, although the change in standard may not formally be retroactive, it nonetheless could have an impact on parents, insurers and courts who may well treat the revision as applying to all existing provision. One can speculate that whatever the formal position, the psychological affect could be to make those responsible for play provision – whether in public playgrounds or in school grounds – anxious about their existing provision, no matter that it had not previously been a source of concern.

‘The current standard for the measurement of impact attenuation on playground safety surface systems is based on outdated data and, in light of more recent research, is woefully lacking in its ability to safeguard children using these playgrounds.’

And the suggested motivation for change impeccable:

‘From a more humanistic perspective it will also serve to minimize the risk to countless children and young adults of suffering a TBI from a fall at a playground. To do anything less is an abdication of responsibility by ASTM in general and F08 specifically.’

However, notwithstanding the appeal to the moral high ground, ASTM’s approach, its stated rationale, and the degree to which it has subjected its proposals to a comprehensive risk-benefit analysis is, at the very least, open to question. Thus, precisely because of the gravity and potential negative consequences of the proposal, formal opposition to the suggested change has been registered by the UK Play Safety Forum (PSF), the International School Ground’s Alliance (ISGA), and the British Standards Institute’s Children’s Playground Equipment Committee. What has been quite reasonably requested is that a proper review is conducted that:

‘ would provide a written, publicly-available document for comment by all stakeholders. In our view such a review should contain:

‘A clear statement of aims of the measure / intervention

the scientific evidence

a quantification of the effectiveness of the measure

an account of the costs of the measure and who would bear them

an examination of any unintended consequences including consideration of wider implications e.g. effects on play value, health and well being of children and the probable effects on the amount of play provision.

A decision should then only be taken after comments have been received and considered.’

The quote above in italics is from the UK PSF’s letter to the relevant ASTM committee. The ISGA letter is couched in similar terms. What is important to note is that the request is for a public, transparent, comprehensive examination of the issue under view. Something significantly wider – and more open – than is accommodated by ASTM processes.

This all raises questions about the degree to which decisions by in particular play equipment and surfacing Standard-making bodies[1] can be considered authoritative, an issue likely to be exacerbated should the proposed Transatlantic Trade and Investment Partnership (TTIP) treaty be ratified. But irrespective of TTIP, standards are sufficiently international in practice for those responsible for play provision – the ‘absent voices’ – across jurisdictions to now take an active role in opposing insufficiently scrutinised changes. I and others would certainly be happy to support such moves.

Wherever you are – there is small chance at present of escape

Do not imagine that the effects of any change in American standards will not ultimately affect you, wherever you are. Standards are increasingly international – what is decided in one jurisdiction pretty quickly affects others. This is because one of the overriding goals of Standards generally is ‘harmonisation’; that is, ironing out the difference between different countries’ Standards and specifications in order to facilitate free trade.

End word

Earlier in this piece I quoted from the UK Play Safety Forum’s letter to the ASTM sub-committee. Below I share in full the International School Ground Alliance’s letter. To my mind it is significant that ISGA encompasses a range of practitioners in play, from designers to teachers to natural play environment proponents and more besides. I would encourage others to make representations either individually or organisationally. Do share the information if you do.

The International School Grounds Alliance Letter

By email: Harvey C Voris (hvoris@paramountfitness.com)

03 December 2014

Harvey C Voris.

ASTM Sub Committee FO8.63,

Paramount Fitness Corporation,

8381 Deepcliff Drive,

Huntington Beach,

CA 92646

USA

Dear Mr Voris,

Proposal to reduce HIC1000 to HIC700

I am writing to you on behalf of the International School Grounds Alliance (ISGA) Leadership Council in your capacity as Chairman of the ASTM sub-committee F08.63 responsible for Children’s Playground Surfacing.

The ISGA is an international network of educational, play, environmental organisations and authorities, along with landscape architects. The ISGA’s membership comprises organisations and individuals working in the USA, Canada, Europe, Africa and the Antipodes and has day to day experience of the widest possible range of play places across a range of settings, from schools, to parks to nature reserves, and more. The ISGA’s commitment to play and its role in assuring children and teenagers’ well-being is set out in the accompanying Westerbeke Declaration, also found at http://www.greenschoolyards.org/.

We learn with concern that ASTM is to consider reducing the HIC Value of Impact Absorbing Surfaces for children’s play from HIC1000 to HIC700. We question both the process by which ASTM reaches its decisions, and the substance of the proposal itself. It is our strong view that there should be no premature judgment in this matter.

We note the potential negative, severe consequences if such a reduction in HIC values is agreed. These include, but are not limited to, the potential additional costs to provide play opportunities – and the possible reduction in the same given limited, and often decreasing, budgets – and the curtailing of a range of children and teenagers’ beneficial play experiences.

We therefore endorse the approach of the UK Play Safety Forum in its letter to you and, with them, request that a proper, impartial, publicly available review of the proposal is undertaken before any conclusion is reached as to the desirability of the proposed reduction in HIV values. Such a review should include:

a clear statement of aims of the measure / intervention

the scientific evidence

an account of the financial costs of the measure and who would bear them

a comprehensive risk-benefit analysis including consideration of wider implications e.g. effects on play value, health and well being of children and the probable effects on the amount of play provision.

A decision should then only be taken after comments have been received, published and considered by a wide range of stakeholders.

The fact that the ISGA Leadership Council is writing to you is a measure of the importance we give to this matter, along with our firm conviction that premature judgment in this matter will not serve the best interests of children and teenagers.

We look forward to your response.

Yours sincerely,

Bernard Spiegal

for and on behalf of the ISGA Leadership Council

Replies in the first instance to Bernard Spiegal, info@playlink.org

[1] For the avoidance of doubt it is probably worth me saying that I don’t doubt that Standard-making bodies have authority and legitimacy in terms of their self-generated structures and procedures. What is in doubt is their authority, as currently constituted, to affect matters that have wider social policy implications.

36 responses to “A real and present danger to play provision”

Bernard,
Your hyperbole is breathtaking:
“There is something distinctly biblical about the process of formulating Standards: it puts me in mind of Moses on Mount Sinai, out of sight to the multitudes below, cooking up with God the written ten commandments (and, lest you forget, 613 oral ones) and then delivering them to the not altogether enthusiastic People at mountain’s foot who nevertheless agree, perhaps in bemusement, to adhere to them.”
Seriously? My experience in standards development is that Technical Committees welcome input from standards users and that most technical committee meetings are open for observation. All that is needed is a request to the committee to come to a meeting. Working Group meetings may be closed, however, stakeholders are encouraged to review draft documents and comment on them. Again, all that is needed is a request to the committee so that your interest is known.
There is little that could be considered Biblical in the process, and unfortunately, while risk in play is clearly beneficial, this kind of hyperbolic language does little to advance the discussion.

Doug, hello, we have not met and know not each other. However, its good of you to take the time to pen a comment, and on a 2015 article.

I’ll not adjudicate as to whether the quote highlighted is in fact hperbolic, but I stand by the point made, which is that in practice – stress ‘in practice’ – standards are developed within structures and processes that are to a significant degree exclsionary, whether that is the intent or not.

Lord Justice Mathew made the telling point that ‘In England justice is open to all, like the Ritz.’ And thus it is with standards’ committees: you need financial muscle to be able to attend, which accounts in part why commercial interests are well represented. There is also the wider question of the value-base and objectives of standard’s committee as currently constituted.

I am acquitted with David Ball through the work that is starting in ISO TC83/WG6. To some extent I agree with you regarding the financial cost – I am in independent consultant with a micro business, and there are times when the costs can be overwhelming – I sit on four ISO committees, two IEC committees, and four CSA committees, including holding the Chair for two. Canada makes this a bit easier in that there are some subsidies available to cover travel costs to meetings, but all the rest of the costs of participation are mine. It seems to me that if the topic is of sufficient importance, one finds a way to get involved, even if it is as an interested stakeholder reviewing drafts and submitting comments.

I know from spending a few hours on your blog that you have been waging a campaign for many years on this topic. I am interested in finding middle ground, where the things that can and should be standardized are, and where the things that should be left alone are left alone. My biggest frustration is that I am hearing plenty of complaints from the risky play advocates, but no real proposals for what might be done. In my opinion, if you want to point out a problem, then you are well advised to also bring some potential solutions for consideration. If you are in a place to propose something, I’m sure there can be opportunities for those ideas to be given a fair hearing.

You say, ‘My biggest frustration is that I am hearing plenty of complaints from the risky play advocates, but no real proposals for what might be done.’

But the contrary is the case. The process of Risk-Benefit Assessment has been widely discussed, and increasingly deployed. It has the imprimatur of the UK Play Safety Forum, an acknowledged international leader in the area of risk-taking in play and the need to take account of benefits as integral to any assessment of what constitutes an acceptable level of risk. (Declaration of interest: Professor David Ball, Tim Gill and myself are advisers to the forum.) RBA rests on a robust conceptual base and, beyond this is, as indicated above, proving its practical worth across a range of play provision providers. The more salient question is why standard committees have been slow to endorse and promote it, or to use RBA as an apt vehicle for analysing their own assumptions and practice?

You say, too, that you are ‘interested in finding middle ground, where the things that can and should be standardised are, and where the things that should be left alone are left alone.’

Clearly, you see that there is a distinction to be drawn between what standards can usefully do, and what they can’t, the implication being that they are already guilty of trespass or over-reach into areas where they should not venture.

I’m not convinced that the ‘middle ground’ is what needs to be sought. Rather, an alternative conceptual framework to the one standard committees appear to operate under needs to be articulated. This has been done in the peer reviewed paper ‘Children’s Play Space and Safety Management Rethinking the Role of Play Equipment Standards’ (D. Ball, T. Gill, H. Harbottle, B. Spiegal) and can be found here: http://journals.sagepub.com/doi/abs/10.1177/2158244014522075

So, the problem appears not to be the absence of an alternative robust conceptual framework to the one presently holding sway, nor the absence of a process – RBA – theoretically sound, and of demonstrable utility, but the inability or unwillingness of standard-generating committees to be more self-critical both of their assumptions and of their practice.

Should’t we design for PERCEIVED risk and danger? I mean – I guess auto manufacturers can design seatbelts for a car – but just don’t have them attached to the frame. As an industry – we have discovered that kids fall down – which is no big deal – but – as you read this – seated in your nice comfy chair – just feel “safe” – that there is (probably) an ASTM standard for the attaching hardware in your chair…

Second, I strongly object to your characterization of standards committees as resistant to considering RBA. The problem is that, at least so far, no one has articulated RBA as a proposal that could be considered. There is an opportunity here that I encourage you and Professor Ball to take. It is my personal opinion that ISO TC83/WG6 will be open to hearing your ideas IF they are proposed in a way that can be implemented. So there is the challenge. A reasonable and rational debate can then take place in committee, and we can see where that goes. I can arrange to have you invited as a guest expert if you’re interested.

Gang – hold the Fort…here is the deal…THIS IS ALL ABOUT Performance Standards – warranties – guarantees – these are all critical. Is there anyone reading this that would not agree that if you buy something – anything – that you should be aware of the warranty – the guarantee – the performance standard? Go ahead – buy a new car that has a 90 day warranty for seat belts and airbags…then put your 16 year old child in it as a new driver!

A deck on a playground…what is the warranty? 50 years? The steel posts supporting the decks- what is the warranty.. 50 years? The rotationally molded plastics affixed to a deck…what is the warranty? 15 years? The Surfacing under the decks – under the plastics…what is the warranty? Hmmmmmm – THAT IS THE ZILLION DOLLAR QUESTION.

It is foolish to spend $100,000 on equipment that has extensive warranties – and then spend $100,000 on unitary surface that has a BOGUS (practically non-existent warranty)…People need to be aware of the warranties…there are some warranties that are short – some very long. Research.

The movement to lower HIC to 700 – is simple – it is the only way (that I know of) – that you can pass along a Performance Standard and Warranty to the purchaser that just spent $100,000 on rubber….so there is some longevity to it’s performance – meaning – fall protection not exceeding 1,000 Also things like seam separation – curling of tiles – shrinkage – pebbling – etc etc. FOR YEARS.

I would vote for maintaining the 1,000 – if – the ASTM standard mandated a warranty period for performance.

Anyone that thinks Performance Standards for surfacing in not critical – then you also have to vote against the ASTM equipment standards – and lobby that the performance standard of the equipment – match the performance standard of the surfacing. Let’s rally the troups to cheapen the decks – decrease the thickness of the hardware – go cheap cheap cheap…

Or – we hold manufacturer’s to a standard of Performance – and have crystal clear warranties/guarantees – to protect the investment communities make.

I’m gonna take a guess here and state if the ASTM had a performance standard for surfacing – that read “Surfacing not to exceed 200 gmax/1,000 HIC – from 5 years of installation….what you would see are surfaces that are in the 700HIC range upon installation – and not the “998 barley passed) junk!

You all seem to be missing the most important factures behind this proposed reduction in the HIC. As for safety concerns and reducing overall injuries, poured in place rubber surfacing, especially taking in to account the relatively short life span of this very expensive material, is, in fact, a poor choice. The effectiveness and the test methods for establishing that effectiveness, are so controlled and misrepresented, that they boarder on unlawful practices. For a true picture of the effectiveness of this material, testing should be done in the field taking into account all the other factures, like, wear and tear, age of users and material, weather conditions etc. to get a true picture. The call for the reduction is evident enough that what we are doing now isn’t working. The second point to be made, this proposal and poured in place rubber surfacing in general, is all about money more than protecting our children.

Bernard – I agree whole-heartedly – the EQUIPMENT seems to have firm performance standard – but the RUBBER – not so much…It is time to hold the UNITARY surfaces groups – accountable – and mandate Performance Standards and transparency to the client…Unless something is devised – the only other thing I can think of – is to mandate a LOWER GMAX/HIC upon installation – and then a warranty period where the GMAX/HIC does not exceed the magical N.T.E. numbers of 200/1000.

Two weeks ago – I was at a day care – we are proposing a new rubber system – I reviewed the Performance Standard and the guarantees we offer….she was shocked when I said 6 years full – then years 7-10 prorated (materials/and N.T.E. 200/GMAX)….she informed me that the day before – another rubber company came in – and they proposed rubber – and gave them a “lifetime” warranty. I asked her to contact them and ask what “lifetime” meant.

How is the use of this rubberized matting related to accessibility standards in the U.K. or elsewhere? Here in TO, it has become the assumed material for wheelchair accessibility – its alleged safety features are viewed as an additional benefit, because we all really do prefer sand. Any thoughts or comments on this?

My hope is that others may see your question and my response, and add to – and perhaps oppose – what is said here.

Underpinning what I say is my understanding of the specifically UK approach to legislation in this and other areas. In principle, UK law allows for flexibility of response, consideration of local circumstances, and it should be able to take into account the overall objectives of, in this case, play provision. (I say ‘in principle’, more on this below.)

Our legislation enshrines the principle of ‘reasonableness’ and ‘reasonable care’ in carrying out the duties in disability legislation. Thus, this from a Forestry Commission (Scotland) publication: ‘…it is essential to bear in mind that the legal application of the word ”reasonable” is a flexible one as it has to take into consideration the differing needs of the wide variety of disabilities, the extent of necessary alterations to facilities and, subject to case law interpretation, the cost of such alterations.’ (Quote drawn from Forestry Commission, Scotland, publication at http://www.forestry.gov.uk/pdf/OPENspace_Disabled_access_Task1.pdf/$file/OPENspace_Disabled_access_Task1.pdf)

Notwithstanding that there is potential flexibility, it is also the case that play provision providers respond sometimes – often-times? – to what they see as their obligations in respect of disability legislation in a mechanistic and formulaic way. As in other fields this is, to my mind, part of wider ‘flight from judgment’ syndrome, a retreat into the apparent comfort of detailed, blanket, context-free stipulations.

By way of an all too present current example, we are in the process of responding to a Tender Document from a Wildlife Trust the aim of which is to encourage children and teenagers to have a wider engagement with nature. Yet they have stipulated that paths must be laid to all play features. I think this wrong and muddle-headed.

There is also what we might call a conceptual difficulty: play provision says of itself that it is about creating opportunities for kids to experience challenge and risk-taking. A challenge only has meaning if it is not easily achieved; that one can ‘fail’ in meeting whatever challenge one happens to attempt and that, perhaps at a future time, when one is older, bigger, braver, more practiced, the challenge can be vanquished. This means that failure, or its threat, is part of the deal.

This perspective seems to me to lead to the understanding that meeting the needs and wants of disabled kids is necessarily about striking balances and accepting that there will be trade-offs but this is, critically, within a value system that holds that all children and teenagers have the right to play. This of course is the language of risk-benefit assessment, a process that is predicated on the requirement to make judgments.

I’m puzzled by the intrusion of ideas about the assumed safety benefits of rubber matting in the context of accessibility, which I assume refers to its use in paths. Seems a non-sequitur to me; surely lots of surfacing materials are just fine if ‘safety’ is an issue. Is there a muddle being perpetrated here? It’s one thing to think, indeed demand, that play provision as such should be accessible to disabled kids – i.e. easy access to the provision – as distinct from the belief that each play feature/equipment should be easily accessible.

Finally, I did take a peek at some Canadian documents (lost links, sorry), one says, ‘These guidelines do not have any legal status and compliance with them should not be regarded as complying with the DDA, but they will provide guidance on established best practice in a general sense that relevant organizations can apply to their particular situation.’

And elsewhere I did see reference to ‘reasonableness’: for example, ‘Since October 1999 service providers have had to take reasonable steps to change practices, policies and procedures which make it impossible or unreasonably difficult for disabled people to use a service…’

Might this mean that the issues are, at least in part, about how law is interpreted; along with the need to counter the lazy practice that treats non-statutory guidelines as unchallengeable mandatory requirements?

And does mean there is scope for the formulation of alternative, authoritative guidance on play provision and disability, one that starts by explaining why issues of accessibility and the ability of disabled people to use facilities in respect of, say, schools or theatres, are different in kind to that of play provision, accepting, of course that ease of access into the provision needs to be secured?

Is there any information on the true full-cycle cost of rubberised/wet-pour IAS? I’m thinking full environmental impact from manufacture to installation to removal and disposal. And am I right in thinking that the original tests and specifications were developed by a safety section of the Greater London Council which modelled vertical head-first falls? Using coconuts among other attempts to replicate skull impacts?

Thanks to David (Professor David Ball) for helping me respond to your questions. (I should add that final comments in this response are my responsibility alone.)

In terms of life cycle of IAS-rubber, appears that no such study has been conducted. You are in good company if you think this is something that should be done. Rubber surfacing contains isocyanates – in the early days of laying these products the air was monitored for these emissions to protect workers. But, so far is known, other potential impacts on children and the environment have not been assessed.

David confirms that you are right or nearly so about GLC involvement. Work on rubber surfacing was done by Graham Tipp and Vic Watson who were rubber technologists / materials scientists. They did not measure any head first impacts themselves,’with or without coconuts. They borrowed American research which had used corpses, volunteers, and animals which gave some idea of the g forces which the skull could withstand. This is described in ‘A holistic approach to accident and injury prevention in children’s playgrounds,’ by Karen King and David Ball, published by GLC in 1989.

(And, I add, ASTM continues in the tradition of basing its proposals on data drawn from sources some distance from consideration of children and teenagers’ behaviour, competencies; and ASTM is seemingly blind to the idea that injury reduction is but one, not necessarily a pre-eminent, social goal in respect of play provision. Thus, from ASTM web site’s Rationale for a reduction in HIC value from HIC1000 to HIC700, ‘A child falling on his/her head has a 2% cumulative chance of death. Using existing research and data the HIC value in the ASTM F1292 standard should be lowered from 1000 to 700. This is based on the current NHTSA standard for dummies used in car crash simulations.’

My interest here is that both sides of the argument pray in aid of their particular view a judgment based on a ‘benefit-risk’ assessment – leading to two competing conclusions. This is important, for it reminds us that there is a point where the evidence runs out and we are forced back into ‘civil society’ considerations that are at base of a social/ethical/political/value-based dimension. And here there will always be contention, and the evidence will not help us, or perhaps only partially so.

Civil society considerations, or public ethics, to put it another way. You have made that point before, sir, and please keep making it.

What do we want for our children,, for our children? What do we want for our society!

“This is important, for it reminds us that there is a point where the evidence runs out and we are forced back into ‘civil society’ considerations that are at base of a social/ethical/political/value-based dimension. And here there will always be contention, and the evidence will not help us, or perhaps only partially so.”

Some very nice and cogent troop-rallying, Mr S. It’s going to be an uphill battle to get the UK play works to grasp the bigger civic picture. Personally I would not have attempted it, which is not to say that I don’t wish you well and that I don’t agree. Needs doing. Power. Elbow.

Cogency especially in your response to comments. I pray for the day when you can be less prolix and more ‘executive summary’, but I would not countenance that personality change for one instant if it were at the expense of your erudition and—what’s the word I’m looking for that means relentless attention to detail and unassailably logical structure—‘spiegality’? Spiegeliciousness?

Arthur, thanks for the encouragement. I think the effort worthwhile and aim to keep nose to the grindstone. Of course, there comes a point when it is futile to wave to people who aren’t there, but I detect mild bestirrings. We shall see.

As to the charge of prolixity, I refute it, though the charge has been laid against me by at least one other other eminence who has visited this blog’s (blog: such an ugly word)comment section. For myself, I shall continue in the delusion that all my pieces are erudite and perfectly formed. Actually, as you surely know, one needs to be at least a little delusional to sustain any sort of effort that aims to provoke change. ‘Reasonableness’ may be – I should say ‘is’ – a good principle in terms of the law. But perhaps not always so in the politics of change.

I have to agree with Bernard’s objectives here….to openly re-examine the underlying assumptions concerning safer surface…..the unexpressed givens…the industrial and professional prejudices. I have to personally admit to resenting significant percentages of ever diminishing play budgets ending up poured onto the ground at the expense of more and better play opportunities. Research I carried out in the 1990’s to explore children’s attitudes to safer surfacing did not find evidence that rubber was the best solution. The children in fact preferred sand….it was safe, playable, “quieter”, and kept wheeled toys away from play structures. Open sand play areas were rarer then than is the case now. For the children using these playgrounds, the significant bonus was ‘playability’…not safety…..nor to ameliorate litigation concerns. Accessibility could be addressed by other means or sand decks. Sand is also sustainable and a natural material…surely a better solution despite maintenance implications….though is not a few tons of comparatively cheap sand each year better play value and cheaper than rubber tarmac? And is not better ‘play’ our objective….and risk in play is synonymous?

Jerry, thanks. It will hardly be a surprise that I agree with the points you make. But you also touch on another issue that would benefit from further thought and discussion. The issue is that of ‘accessibility’ in particular in relation to disabled kids. To my mind there is too often a ‘standardised’, mechanistic approach to an ‘absolute’: that disabled kids have play needs and wants, as all other kids, and these must be met.

However, this, to my mind, cannot usefully be achieved by simply laying paths to every potential playable opportunity. This is a highly reductive approach, and I should say conceptually flawed.

Hi Bernard. A very informative article. I don’t wish to lessen the potential seriousness of this development, but I do wonder how much actual effect such a change in the detail of the Standards might bring. It seems to me that many play areas these days are completley covered in rubber safety surface, regardless of the type or fall height of the equipment they contain. Or any bit of stand alone equipment has rubber surface surrounding it. Do the people responsible for this even know the specifics of the surface they are installing, or do they just believe that is what they have to do in order to make their play areas ‘safe’ (or less likely to be the subject of litigation, perhaps)? I have spoken to many Parks/Health and Safety people who have no idea that it is primarily used to prevent serious head injuries. They just think it is the standard (safest?) surface to use.
It seems to me that regardless of the specifics of the Standards we need to keep arguing for a more realistic view of what children are capable of and how we responsibly look at the risks that they are allowed to take, as in your paper referred to above, and the recent, excellent RBA approach of Managing Risk in Play Provision.

Nick, thanks for comment. I think you’re probably right that the detail of specification and performance criteria of rubber surfacing is in practice not well understood and, in particular, once laid and in use, not given much attention. At the point of commissioning and initial laying, possibly more attention is given to the technical aspects. And yes, a certain mystique and myth of efficacy attaches to rubber surfacing in particular. It is treated as a signifier of a quality called ‘safe’, and this has some public appeal. The fact that it does have public appeal is one of the reasons why Standards need to become the business of the ‘play world’ in a more active way than has hitherto been the case.

You are right of course to say that the real or underlying issue revolves around views about children’s (and teenagers’) inherent competency and the potential benefits that freely-chosen risk-taking offers.

But I wouldn’t want my agreement with your comments to mask or dilute what I – with others – believe is a significant matter, and that is the question of Standards, the structures and processes of their formulation, the value-system from which they emerge.

I do think – apologies for any repetition – that the ‘play world’, and here I include designers, teachers, playworkers and others, through a mix of bemusement and disdain, have not given play equipment and surfacing Standards the attention they deserve. By default, we have allowed a civil society, value-saturated area of ‘natural’ human activity – play – to be shunted into and entrapped within a seemingly non-public, unaccountable, technically-orientated system of standardisation. Part of the point of my article was to say that ‘we’ need to take responsibility for being an ‘absent voice’ and to amend our error. Simply being critical of Standards may warm us, but it is not a strategy for change.

This is well done. I think its time to rally the troops. Having been a member of the ASTM and attended meetings I can personally attest that the “science” is woefully lacking, committee members all conflicts of interest, consumer or non-industry expertise totally lacking and the process structured to insure that major producers are advantaged.

There is a process within ASTM that allows for the review of Committee actions by the organization itself. This was set up to address such egregious misuse of the standards process. Perhaps this is right avenue to reign in these folks.

Jay, thank you for your useful comment. I am delighted that you refer to ‘rallying the troops’. As may be guessed, I am wholly in favour of that. Indeed it is an urgent task at both national and international levels.

I accept that if ASTM has processes of review and appeal, then may be worth making use of them. More widely, though, there are base-line questions as to the scope and nature of the authority that Standard-making bodies can legitimately claim. (I do not mean to suggest that there is any absence of legitimacy within their own self-generated procedures.) Apologies for repetition, but Standards are a civil society, public policy matter. We have yet to devise structures and processes that reflect this.

Although it may seem cold-hearted to speak about increased cost as a negative consequence of a change in HIC by ASTM, it is highly irresponsible to pursue this when many municipalities and private, play providers are hardly able to afford the cost of maintaining let alone replacing playground surfacing when it comes due. It is a frequent event these days to witness playgrounds where the surfacing is in obvious disrepair and continues in such a state since funds are being redirected at decidedly more “urgent” matters. Play like the arts is seen as a luxury despite all the credence given to issues of liability.
I would also like to add that we are living in a time of grave concern over the welfare of our environment, so while we still do not have a ready solution to dispose of synthetic surfaces. we certainly shouldn’t be compounding the problem by increasing the amount that we use.

David, I do not think it ‘cold-hearted’ to speak of increased cost as a negative consequence since, in the real world, all expenditure decisions in practice are trade-offs between competing claims. That fact is one aspect of the argument that any proposed risk-reduction measure is properly scrutinised and assessed for overall potential benefits – or dis-benefits – taking into account wider social policy goals.

You are right, too, to draw attention to the often low levels of maintenance given to surfacing, or the absence of renewal when worn. Interesting to speculate about whether condition of surface has, overall, any impact on injury rates, their number and severity.

Bernard, your comments and initiative are extremely timely! We are just going into a meeting this morning with city parks officials to discuss accessibility guidelines and why these must be met by blanketing sites with rubberized materials. I will let you know how it went. I have printed your article for the meeting. That should give them cause to pause, I hope.

The long term consequences of this is that children and teenagers will ‘vote’ with their feet! They won’t want to play in a playground where the structures offer them no element of risk and adventure due the size having to be reduced to accommodate the reduce HIC regulation. Which could possibly result in policy makers getting the wrong message of ‘Children and teenagers don’t play on playgrounds anymore.’ Implications are very worrying. Thanks for posting, Bernard.

Jane, thanks for taking time to comment. There is of course the wider question of how Standards affect ‘conventional’ playground design (Makes me wonder, are conventional playgrounds ‘designed’? Does that stretch the term beyond the meaning it can bear?)

I mean by this the point that was made in our joint paper (co-authors: Professor David Ball, Harry Harbottle, Tim Gill, me) referred to elsewhere, that Standards have in effect ‘trespassed’ into areas where they have no real competence. That wider issue needs addressing. Note though, this is not an argument against having any Standards, it is a question of their scope (and the processes of their manufacture)

Bernard, thank you for making this heartfelt plea. And the emotion is important. Safety debates are often portrayed as a matter of head versus heart: the tragic victim or family and their defenders the safety campaigners fighting the forces of unfeeling, remote bureaucracies. But in reality, there are emotional costs on both sides of this argument. Children do lose out when safety measures are poorly thought-through or disproportionate.
As a co-author of the paper Bernard mentions, I echo many of his points. The current debate around ASTM’s move shows that fundamental questions remain unanswered about the creation and evolution of standards: including questions about philosophy, proportionality, scope, legitimacy, accountability, legal status and application.
The Play Safety Forum, the British Standards Institute committee, and the International School Grounds Alliance are respected, authoritative bodies with broad-based experience and expertise. The request from these bodies is simple and reasonable: before we make such a profound change to this standard, we need a wide-ranging, open, transparent review. The review should take proper account of the evidence, acknowledge the complexity of the issues and allow for a much wider range of voices than those who have had a say so far. Anything less may mean that – as the PSF letter says – “the losers will be the children whose world will be no safer, and the public purse, which will be poorer.”

Thanks for commenting. It will surprise neither of us that we are, on this matter, in agreement.
This is perhaps (one of) the moments to note the immediate, and potential long term, significance of PSF, ISGA, and the BSI making formal representations to ASTM. Some great stirring may be afoot. Others need to become part of this wider involvement in an area that has hitherto been deemed somewhat esoteric and specialist (apologies for those who tire of me repeating this point yet again)

Thanks for this Bernard. I am saddened to be reminded of the strange approach of adults to those that they deem so far below them in sense and ability – that is – children. It is really obvious to say that we can protect those less able than us by putting them in a padded cell and ensuring they cannot physically hurt themselves, it may even seem logical to those who have a very limited view of what ‘hurt’ looks like. It seems to me to be part of a desire of adults to ensure they are not responsible for any injury that a child may sustain in the course of its life and also to minimise the tragedy of life.
This may well seem like a beneficent aim but, I would argue, not in our gift.

Anita, that point about responsibility – ‘…to be part of a desire of adults to ensure they are not responsible for any injury…’ –
is an interesting one. It suggests that adults/parents have recast ideas about responsibility away from ideas of, for example, fostering resilience, a theme many of us including not least you and Tim, speak about with conviction – and a degree of urgency.

I’m not sure how effective we are in convincing people/parents to take a wider view of what ‘taking responsibility’ might mean. Seems to me any ‘victories’ in this regard are local and fragile. This does link to a wider consideration of how ‘parenting’ – an ‘ugh’ term, methinks – is conceived; and the pressures parents are under to perform in particular ways. The school system seems to have appropriated parents’ into their performance management regimes, what with Ofsted regaling parents on child absences, bedtime stories and homework. Parents are under pressure, they feel watched and assessed, by the state, its agencies, and neighbours (would you let your young child go to the local shops and risk local censure? In your case, I think the answer is you would!